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Process Guidance Note 3/18(12)
Statutory guidance for mineral drying and cooling
September 2012
© Crown copyright 2012
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Defra would like to acknowledge the work of the
Environment Agency‟s Local Authority Unit in the
drafting of this guidance note.
Process Guidance Note 3/18(12)
Statutory guidance for mineral drying and cooling
Revision of the guidance
The electronic version of this publication is updated from time to time with
new or amended guidance. Table 0.1 is an index to the latest changes
(minor amendments are generally not listed).
Table 0.1 - Revision of the guidance
September 2013
PG3/18 Publication version
Lines 7&8 of Table 4.1
and 10&11 0f Table 1 in
Model Permit
Replace “indirect” with
“indicative”
i
Contents
Revision of the guidance .................................................................................................................. i
Contents ......................................................................................................................................... ii
1.
Introduction ......................................................................................................................... 1
Legal basis .................................................................................................................................. 1
Simplified or standard permits...................................................................................................... 2
Who is the guidance for? ............................................................................................................. 2
Updating the guidance ................................................................................................................. 3
Consultation................................................................................................................................. 3
Policy and procedures ................................................................................................................. 3
When to use another note rather than PG3/18............................................................................. 3
2.
Timetable for compliance and reviews ................................................................................. 4
Existing processes or activities .................................................................................................... 4
Permit Reviews ............................................................................................................................ 5
3.
Activity description ............................................................................................................... 6
Regulations.................................................................................................................................. 6
4.
Emission limits, monitoring and other provisions ............................................................... 10
Monitoring, investigating and reporting ...................................................................................... 13
Information required by the regulator ......................................................................................... 13
Visible Emissions ....................................................................................................................... 14
Emissions of Odour ................................................................................................................... 15
Abnormal Events ....................................................................................................................... 15
Start up and shutdown ............................................................................................................... 16
Continuous Monitoring ............................................................................................................... 16
Calibration and compliance monitoring. ..................................................................................... 17
Varying of monitoring frequency ................................................................................................ 18
Monitoring of unabated releases ................................................................................................ 19
Representative sampling ........................................................................................................... 19
5.
Control techniques ............................................................................................................ 20
Summary of best available techniques....................................................................................... 20
Techniques to control emissions from contained sources .......................................................... 21
Air Quality .................................................................................................................................. 29
Management.............................................................................................................................. 31
6.
Summary of changes......................................................................................................... 33
7.
Further information ............................................................................................................ 34
Sustainable consumption and production (SCP) ........................................................................ 34
Health and safety ....................................................................................................................... 34
Further advice on responding to incidents ................................................................................. 35
Appendix 1 - Application form ....................................................................................................... 36
Appendix 2 - Model Permit ............................................................................................................ 47
List of Tables
Table 0.1 - Revision of the guidance ................................................................................................ i
Table 2.1 - Compliance timetable.................................................................................................... 4
Table 3.1 - Regulations listing activities .......................................................................................... 6
Table 4.1 - Emission limits, monitoring and other provisions ......................................................... 11
Table 5.1 - Summary of control techniques ................................................................................... 20
Table 6.1 - Summary of changes .................................................................................................. 33
Table 4.1 - Emission limits, monitoring and other provisions ......................................................... 51
List of Figures
Figure 3.1: Typical arrangement of a sand dryer and cooler ........................................................... 8
Figure 3.2 Typical industrial sand fluid bed drying process ............................................................ 9
Figure 3.3 Diagram of general purpose rotary dryer setup ..................................................................... 9
PG3/18 Publication version
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1.
Introduction
Legal basis
1.1
This note applies to the whole of the UK. It is issued by the Secretary of
State, the Welsh Assembly Government, the Scottish Government and
the Department of the Environment in Northern Ireland, (DoE NI), to give
guidance on the conditions appropriate for the control of emissions into
the air from the drying and cooling of minerals sector. It is published only
in electronic form and can be found on the Defra website. It supersedes
PG3/15b (04).
1.2
This guidance document is compliant with the Code of Practice on
Guidance on Regulation page 6 of which contains the "golden rules of
good guidance". If you feel this guidance breaches the code or you
notice any inaccuracies within the guidance, please contact us.
1.3
This is one of a series of statutory notes1 giving guidance on the Best
Available Techniques (BAT)2. The notes are all aimed at providing a
strong framework for consistent and transparent regulation of
installations regulated under the statutory Local Air Pollution Prevention
and Control (LAPPC) regime in England and Wales, Scotland and
Northern Ireland. The note will be treated as one of the material
considerations when determining any appeals against a decision made
under this legislation.
1.4
In general terms, what is BAT for one installation in a sector is likely to be
BAT for a comparable installation. Consistency is important where
circumstances are the same. However, in each case it is, in practice, for
regulators (subject to appeal) to decide what is BAT for each individual
installation, taking into account variable factors such as the configuration,
size and other individual characteristics of the installation, as well as the
locality (e.g. proximity to particularly sensitive receptors).
1.5
The note also, where appropriate, gives details of any mandatory
requirements affecting air emissions which are in force at the time of
publication, such as those contained in Regulations or in Directions from
the Government. In the case of this note, at the time of publication there
were no such mandatory requirements
1
this and other notes in the series are issued as statutory guidance in England and Wales under regulation
64(2) of the Environmental Permitting Regulations. The notes are also issued as statutory guidance in
Northern Ireland and as guidance in Scotland.
2
2 further guidance on the meaning of BAT can be found for England and Wales, Scotland, and Northern
Ireland.
PG3/18 Publication version
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Simplified or standard permits
1.6
Most of the activities covered by this note will have essentially the same
characteristics and it is expected that the application form and model
permit in Appendices 1 and 2 will normally be used in order to simplify
for business the process of applying for a permit and to simplify for
regulators the process of issuing a permit. (See also the LAPPC charging
scheme for reduced application and subsistence charges for simplified
permits).
In the case of activities covered by this note which are mobile plant, it is
expected that regulators will continue to use standard applications and
permits.
If there are good reasons to consider diverging from normal use of the
model permit, the starting point for drafting any additional conditions
should be the arrowed bullets in the main body of this note.
Sites with more than one Pt B activity which in accordance with the
relevant charging scheme are to be treated as a single activity will
require a full permit not a simplified permit, therefore the whole
installation comprising both activities should be subject to a full permit.
1.7
For activities covered by this note which are mobile plant, in Section 4
and Section 5, arrows are used to indicate the matters which should be
considered for inclusion as standard permit conditions. It is important to
note, however, that this should not be taken as a short cut for regulators
to a proper determination of BAT or to disregard the explanatory material
which accompanies the arrows. In individual cases it may be justified to:

include additional conditions

include different conditions

not include conditions relating to some of the matters indicated
In addition, conditions will need to be derived from other parts of the
note, in particular to specify emission limits, compliance deadlines and
mandatory requirements arising from directions or other legislation.
Who is the guidance for?
1.8
This guidance is for:
Regulators

local authorities in England and Wales, who must have regard to the
guidance when determining applications for permits and reviewing
extant permits;

the Scottish Environment Protection Agency (SEPA) in Scotland, and
district councils or the Northern Ireland Environment Agency, (NIEA),
in Northern Ireland.
PG3/18 Publication version
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Operators who are best advised also to have regard to it when making
applications and in the subsequent operation of their installation.
Members of the public who may be interested to know what the
Government considers, in accordance with the legislation, amounts to
appropriate conditions for controlling air emissions for the generality of
installations in this particular industry sector.
Updating the guidance
The guidance is based on the state of knowledge and understanding, at
the time of writing, of what constitutes BAT for this sector. The note may
be amended from time to time to keep up with developments in BAT,
including improvements in techniques, changes to the economic
parameters, and new understanding of environmental impacts and risks.
The updated version will replace the previous version on the Defra
website and will include an index to the amendments.
1.9
Reasonable steps will be taken to keep the guidance up-to-date to
ensure that those who need to know about changes to the guidance are
informed of any published revisions. However, because there can be
rapid changes to matters referred to in the guidance – for example to
legislation – it should not be assumed that the most recent version of this
note reflects the very latest legal requirements; these requirements
apply.
Consultation
1.10
This note has been produced in consultation with relevant trade bodies,
representatives of regulators including members of the Industrial
Pollution Liaison Committee, and other potentially-interested
organisations.
Policy and procedures
1.11
General guidance explaining LAPPC and setting out the policy and
procedures is contained in separate documents for England and Wales,
Scotland and Northern Ireland.
When to use another note rather than PG3/18
1.12
This note does not cover quarrying activities.
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2.
Timetable for compliance and reviews
Existing processes or activities
2.1
This note contains all the provisions from previous editions which have
not been amended or removed. For installations in operation at the date
this note is published, the regulator should have already issued or varied
the permit having regard to the previous editions. If they have not done
so, this should now be done.
2.2
The new provisions of this note and the dates by which compliance with
these provisions is expected are listed in Table 2.1, together with the
paragraph number where the provision is to be found. Compliance with
the new provisions should normally be achieved by the dates shown.
Permits should be varied as necessary, having regard to the changes
and the timetable.
Table 2.1 - Compliance timetable
Guidance
Relevant paragraph/row in
this note
Compliance date
There are no new provisions in this note likely of themselves to result in a need
to vary existing permit conditions. For a full list of changes made by this note,
excluding very minor ones, see Table 6.1.
2.3
Replacement plant should normally be designed to meet the appropriate
standards specified for new installations/activities.
2.4
Where provisions in the preceding guidance note have been deleted or
relaxed, permits should be varied as necessary as soon as reasonably
practicable. It is expected that local authorities will aim to vary existing
permits so as to convert them into the model permit format in Appendix 2
within 12 months of the publication of this note.
2.5
For new activities, the permit should have regard to the full standards of
this guidance from the first day of operation.
2.6
For substantially changed activities, the permit should normally have
regard to the full standards of this guidance with respect to the parts of
the activity that have been substantially changed and any part of the
activity affected by the change, from the first day of operation.
PG3/18 Publication version
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Permit Reviews
2.7
Under LAPPC, the legislation requires permits to be reviewed
periodically but does not specify a frequency. It is considered for this
sector that a frequency of once every eight years ought normally to
be sufficient for the purposes of the appropriate Regulations3. Further
guidance on permit reviews is contained in the appropriate Guidance
Manual for England and Wales, Scotland and Northern Ireland.
Regulators should use any opportunities to determine the variations
to permits necessitated by paragraph 2.2 above in conjunction with
these reviews.
2.8
Conditions should also be reviewed where complaint is attributable to
the operation of the process and is, in the opinion of the regulator,
justified.
3
For details see England and Wales General Gguidance Manual chapter 26, Scotland, Practical guide
section 10, Northern Ireland Part B Guidance page 9, Northern Ireland Part C Guidance chapter 17.
PG3/18 Publication version
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3.
Activity description
Regulations
3.1
This note applies to LAPPC installations for the drying and cooling of
minerals sector. The activities for regulation are listed in Table 3.1.
Table 3.1 - Regulations listing activities
LAPPC
Activity
England and
Wales
Scotland
Northern
Ireland
EPR Schedule
1 reference
PPC
Schedule 1
reference
PPC
Schedule 1
reference
Part A
Combustion Section 1.1
over 50MW Part A1
site
aggregated
Section 1.1
Part A
Section 1.1
Part A
Part B
Drying and
cooling
minerals,
combustion
less than
Part A
Section 3.5
Part B
Section 3.5,
Part B
Section 3.5
Part B
Part C
Drying and
cooling
minerals,
combustion
less than
Part A
n/a
n/a
n/a
The links are to the original version of the regulations. A consolidated
version is not available on www.legislation.co.uk
3.2
This note refers to the drying, cooling, screening, grading and size
reduction of minerals. It also refers to any ancillary handling of
materials which takes place as part of these processes.
3.3
This note includes the combustion of oil that complies with the Quality
Protocol for processed fuel oil. Combustion of waste oil is not
covered by this note; it is regulated in Part A and the Waste
Incineration Directive applies.
3.4
Extraction of sand and gravel, and the associated washing, grading
and screening, is not intended to be a prescribed process, as in
normal operation the process is unlikely to result in the release into
air of particulate matter.
PG3/18 Publication version
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3.5
Where sand is extracted and dried at the same site, the drying
installation is likely to include the stockpiles of sand awaiting drying
but not likely to include the washing and wetgrading or sizing, or any
stockpiles that will be washed and wetgraded or sized.
3.6
Some sand drying plants are located near or in a quarry. This PG
note does not cover quarrying operations.
3.7
This note applies to all new processes, to replacement processes, to
substantial changes to existing processes and the upgrading of
existing processes to meet the new standards of this note.
3.8
3.9
3.10
Sand drying
When sand is quarried it typically has a moisture content of about 6%.
Sand is used in large quantities by the construction industry, in
foundries, by the glass industry and in water filtration and sewage
treatment works. The major uses require different qualities - for
example, in the foundry industry the grade of sand used is critical, in
the glass industry its chemistry is critical. Sand is fed into a dryer
where it is dried according to the customer requirement. It is then
cooled, screened and conveyed via a totally enclosed system to silo
storage.
Fluid bed dryers
Fluid beds are generally used where throughput is 50 - 100 tonnes of
sand per hour. Fluid beds utilise air in generating a fluid bed. The
fluid bed ensures a good transfer of heat from the air to the sand, so
exhaust temperatures are typically quite low at around 48 °C. They
are designed with a large expansion chamber and the dust presented
to the arrestment plant is a fine fraction. In order to keep the
temperature of the emissions above the dew point of around 50 - 60
°C it is often necessary to trace heat the arrestment plant.
Rotary dryers
Rotary dryers tend to be older units and use about 40% more energy
than fluid beds, although there are wide variations due to differences
in type of fuel, moisture content of feed, discharge temperature etc.
Below around 30 tonnes per hour rotary dryers tend to be cheaper
than fluid beds. They are used for throughputs of 30 - 50 tonnes of
sand per hour.
PG3/18 Publication version
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3.11
Mineral drying (other than sand)
As a result of their porous structure other minerals can have a
moisture content up to 30%. Such minerals are dried for use in a
range of industries, including construction, refractory, ceramic and
metallurgical industries. Some operators carry out mineral drying
processes as "jobbers" or “toll manufacturers". This means that they
do not consistently dry one type of material but work to customer
demand. Such operations may involve frequent changes in the
material being dried, and the quantity of any material to be dried will
vary. Occasionally materials are brought in for drying that are
significantly different to materials that have previously been dried on
site e.g. "distressed cargo". It is not always clear whether the
arrestment plant will be capable of meeting the emission
limits/provisions when such unusual materials are being processed.
In such instances it is expected that the operator would carry out a
preliminary evaluation by drying a small quantity of material to
determine that the plant is capable of meeting the provisions. If the
provisions are not met then further material of this type should not be
dried using this plant.
Figure 3.1: Typical arrangement of a sand dryer and cooler
PG3/18 Publication version
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Figure 3.2 Typical industrial sand fluid bed drying process
Figure 3.3 Diagram of general purpose rotary dryer setup
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4.
Emission limits, monitoring and other
provisions
4.1
Emissions of the substances listed Table 4.1 should be controlled.
4.2
The emission limit values and provisions described in this section are
achievable using the best available techniques described in Section 5.
Monitoring of emissions should be carried out according to the method
specified in this section or by an equivalent method agreed by the
regulator. Where reference is made to a British, European, or
International standard (BS, CEN or ISO) in this section, the standards
referred to are correct at the date of publication. (Users of this note
should bear in mind that the standards are periodically amended,
updated or replaced.) The latest information regarding the monitoring
standards applicable can be found at the Source Testing Association
website. Further information on monitoring can be found in Environment
Agency publications (M1) and (M2).
4.3
All activities should comply with the emission limits and provisions with
regard to releases in Table 4.1.
The reference conditions for limits in Section 4 are: 273.1K, 101.3kPa,
without correction for water vapour content, unless stated otherwise.
Table 4.1 should be considered in conjunction with the monitoring
paragraphs found later in this section.
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Row
Table 4.1 - Emission limits, monitoring and other provisions
Substance
Source
Emission
limits/provisions
Type of monitoring
Monitoring
frequency
Sand and Mineral Drying plant
1
Particulate
matter
Sand and Mineral Drying plant, other
than Fluid Bed Dryers
50 mg/m3
EITHER: periodic particulate
monitoring
6 monthly
OR periodic particulate monitoring
Annual
plus: continuously recorded indicative
monitoring
2
Particulate
matter
Sand and Mineral Drying plant, Fluid
Bed Dryers
Where 50mg/m3 is
currently achieved, but
only inconsistently:
100mg/m3 PLUS efforts
should be made to
improve consistency.
3
Particulate
matter
4
Sulphur
dioxide
EITHER: periodic particulate
monitoring
6 monthly
OR periodic particulate monitoring
Annual
plus: continuously recorded indicative
monitoring
No visible emissions
across the site boundary
Operator observations
At least daily
All activities using heavy fuel oil or
other residual type/comparable Quality
Protocol Processed Fuel Oil
1% wt/wt sulphur in fuel
Sulphur content of fuel is regulated under the Sulphur
Content of Liquid Fuels Regulations
All activities using gas oil/ comparable
Quality Protocol Processed Fuel Oil
0.1% wt/wt sulphur in
fuel
Activities burning bio-fuels should have a limit set for sulphur in fuel
Activities burning waste oil not covered by the quality protocol processed fuel oil must comply with the Waste Incineration Directive (WID).
PG3/18 Publication version
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Silos
5
Particulate
matter
Silo inlets and outlets
No visible emission
Operator/driver observations every
delivery. Record start and finish times
Every delivery
Designed to emit less
than 10mg/m3
Arrestment equipment, not serving silos or dryers, and with external discharge points
6
Particulate
matter
Flow 300m3/min or more
Designed to achieve
50mg/m3
recorded filter leak monitoring
Continuous
7
Particulate
matter
Flow more than 100m3/min and less
than 300m3/min
Designed to achieve
50mg/m3
At least recorded indicative monitoring
Continuous
8
Particulate
matter
Flow100m3/min or less
No visible emission
Operator observations
At least daily
Or, recorded indicative monitoring
Continuous
Notes
*All periodic monitoring results shall be checked by the operator on receipt and sent to the Council within 8 weeks of the monitoring being
undertaken.*
(a) The reference conditions for limits in Table 4.1 are: 273.1K, 101.3kPa, without correction for water vapour content.
(b) All periodic monitoring shall be representative, and shall use standard methods.
(c) The emission limits do not apply during start-up and shut down. All emissions shall be kept to a minimum during these periods.
PG3/18 Publication version
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Monitoring, investigating and reporting
4.4
The operator should monitor emissions, make tests and inspections of
the activity. The need for and scope of testing, (including the frequency
and time of sampling), will depend on local circumstances.


The operator should keep records of inspections, tests and
monitoring, including all non-continuous monitoring, inspections and
visual assessments. Records should be:

kept on site;

kept by the operator for at least two years; and

made available for the regulator to examine.
If any records are kept off-site they should be made available for
inspection within one working week of any request by the regulator.
Information required by the regulator
4.5
The regulator needs to be informed of monitoring to be carried out and
the results. The results should include process conditions at the time of
monitoring.

The operator should notify the regulator at least 7 days before any
periodic monitoring exercise to determine compliance with emission
limit values. The operator should state the provisional time and date
of monitoring, pollutants to be tested and the methods to be used.

The results of non-continuous emission testing should be forwarded
to the regulator within 8 weeks of completion of the sampling.

Adverse results from any monitoring activity (both continuous and
non-continuous) should be investigated by the operator as soon as
the monitoring data has been obtained. The operator should:

identify the cause and take corrective action;

clearly record as much detail as possible regarding the cause
and extent of the problem, and the remedial action taken;

re-test to demonstrate compliance as soon as possible; and
inform the regulator of the steps taken and the re-test results.
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Visible Emissions
4.6
4.7
The aim should be to prevent any visible airborne emission from any part
of the process. This aim includes all sites regardless of location.
Monitoring to identify the origin of a visible emission should be
undertaken and a variety of indicative techniques are available.

Where ambient monitoring is carried out it may also be appropriate
for the regulator to specify recording of wind direction and strength.

Where combustion units are in use for dryers then the combustion
process should be controlled and equipment maintained as
appropriate.
Emissions from combustion processes should in normal operation be
free from visible smoke. During start up and shut down the emissions
should not exceed the equivalent of Ringelmann Shade 1 as described in
British Standard BS 2742.

All other releases to air, other than condensed water vapour, should
be free from persistent visible emissions.

All emissions to air should be free from droplets.
Where there are problems that, in the opinion of the regulator, may be
attributable to the installation, such as local complaints of visual
emissions or where dust from the installation is being detected beyond
the site boundary, the operator should inspect in order to find out which
part of their operation(s) is the cause.
If this inspection does not lead to correction of the problem then the
operator should inform the regulator in order to determine whether
ambient air monitoring is necessary. Ambient monitoring may either be
by a British Standard method or by a method agreed with the regulator.
Whilst problems are ongoing, a visual check should also be made at
least once per day/shift, by the operator, when an installation is being
operated. The time, location and result of these checks, along with
weather conditions such as indicative wind direction and strength, should
be recorded. Once the source of the emission is known, corrective
action should be taken without delay and where appropriate the regulator
may want to vary the permit in order to add a condition requiring the
particular measure(s) to be undertaken.
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Emissions of Odour
4.8
The overall aim should be that all emissions are free from offensive
odour outside the site boundary, as perceived by the regulator. However,
the location of the installation will influence the assessment of the
potential for odour impact as local meteorological conditions may lead to
poor dispersion conditions. Where the site has a low odour impact due to
its remoteness from sensitive receptors, the escape of offensive odour
beyond the installation would be unlikely to cause harm.
Where there are problems that, in the opinion of the regulator, may be
attributable to the installation, such as local complaints of odour or where
odour from the installation is being detected beyond the site boundary,
the operator should inspect in order to find out which part of their
operation(s) is the cause.
Whilst problems are ongoing, a boundary check should also be made at
lest once per day/shift, by the operator, when an installation is being
operated. The time, location and result of these checks, along with
weather conditions such as indicative wind direction and strength, should
be recorded. Once the source of the emission is known, corrective
action should be taken without delay and where appropriate the regulator
may want to vary the permit in order to add a condition requiring the
particular measure(s) to be undertaken.
Abnormal Events
4.9
The operator should respond to problems which may have an adverse
effect on emissions to air.



In the case of abnormal emissions, malfunction or breakdown leading
to abnormal emissions the operator should:

investigate and undertake remedial action immediately;

adjust the process or activity to minimise those emissions; and

promptly record the events and actions taken.
The regulator should be informed without delay, whether or not there
is related monitoring showing an adverse result:

if there is an emission that is likely to have an effect on the local
community; or

in the event of the failure of key arrestment plant, for example,
bag filtration plant or scrubber units
The operator should provide a list of key arrestment plant and should
have a written procedure for dealing with its failure, in order to
minimise any adverse effects.
PG3/18 Publication version
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Start up and shutdown
4.10
Higher emissions may occur during start-up and shut-down of a process.
These emissions can be reduced, by minimising, where possible, the
number of start-ups and shut-downs and having adequate procedures in
place for start-up, shut-down and emergency shut-downs.

The number of start-ups and shut downs should be kept to the
minimum that is reasonably practicable.

All appropriate precautions must be taken to minimise emissions
during start-up and shutdown.
Continuous Monitoring
4.11
Continuous monitoring can be either “quantitative” or “indicative”. With
quantitative monitoring the discharge of the pollutant(s) of concern is
measured and recorded numerically. For pollution control this
measurement is normally expressed in milligrams per cubic metre of air,
(mg/m3). Where discharge of the pollutant concerned is controlled by
measuring an alternative parameter, (the “surrogate” measurement), this
surrogate is also expressed numerically.
Continuous indicative monitoring is where a permanent device is fitted,
for example, to detect leaks in a bag filter, but the output, whether
expressed numerically or not, does not show the true value of the
discharge. When connected to a continuous recorder it will show that
emissions are gradually (or rapidly) increasing, and therefore
maintenance is required. Alternatively it can trigger an alarm when there
is a sudden increase in emissions, such as when arrestment plant has
failed.
Where continuous indicative monitoring has been specified, the
information provided should be used as a management tool. Where
used, the monitor should be set up to provide a baseline output when the
plant is known to be operating under the best possible conditions and
emissions are complying with the requirements of the permit. Where
used to trigger alarms, the instrument manufacturer should be able to set
an output level which corresponds to around 75% of the emission limit.
Thus the alarms are activated in response to this significant increase in
pollutant loading above the baseline, so that warning of the changed
state is given before an unacceptable emission occurs. The regulator
may wish to agree the alarm trigger level.
PG3/18 Publication version
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4.12
Where continuous monitoring is required, it should be carried out as
follows:

All continuous monitoring readings should be on display to
appropriately trained operating staff.

Instruments should be fitted with audible and visual alarms, situated
appropriately to warn the operator of arrestment plant failure or
malfunction.

The activation of alarms should be automatically recorded.

All continuous monitors should be operated, maintained and
calibrated (or referenced, in the case of indicative monitors) in
accordance with the manufacturers‟ instructions, which should be
made available for inspection by the regulator. The relevant
maintenance and calibration (or referencing, in the case of indicative
monitors) should be recorded.

Emission concentrations may be reported as zero when the plant is
off and there is no flow from the stack. If required a competent
person should confirm that zero is more appropriate than the
measured stack concentration if there is no flow.

Any continuous monitor used should provide reliable data>95% of
the operating time, (i.e. availability >95%). A manual or automatic
procedure should be in place to detect instrument malfunction and to
monitor instrument availability
Calibration and compliance monitoring
4.13
Compliance monitoring can be carried out either by use of a continuous
emissions monitor (CEM), or by a specific periodic test carried out at a
frequency agreed with the regulator.
4.14
Where a CEM is used for compliance purposes it must be periodically
checked, (calibrated), to ensure the readings being reported are correct.
This calibration is normally done by carrying out a parallel stand-alone
periodic test and comparing the results with those provided by the CEM.
4.15
For periodic testing the sampling should meet the following requirements:

For batch processes, where the production operation is complete
within, say, 2 hours, then the periodic sampling should take place
over a complete cycle of the activity; and

For all activities the sampling period should be sufficient such that at
least 3 results are obtained.
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4.16
4.17
Should the activity either be continuous, or have a batch cycle that is not
compatible with the time available for sampling, then the data required
should be obtained over a minimum period of 2 hours in total.

For demonstration of compliance where a CEM is used no daily
mean of all 15-minute mean emission concentrations should exceed
the specified emission concentration limits during normal operation
(excluding start-up and shut-down); and

no 15-minute mean emission concentration should exceed twice the
specified emission concentration limits during normal operation
(excluding start-up and shut-down).

For periodic testing, no result of monitoring should exceed the
emission limit concentrations specified.
Exhaust flow rates should be consistent with efficient capture of
emissions, good operating practice and meeting the requirements of the
legislation relating to the workplace environment.

The introduction of dilution air to achieve emission concentration
limits should not be permitted.
Dilution air may be added for waste gas cooling or improved dispersion
where this is shown to be necessary because of the operational
requirements of the plant, but this additional air should be discounted
when determining the mass concentration of the pollutant in the waste
gases.
Varying of monitoring frequency
4.18
Where non-continuous quantitative monitoring is required, the frequency
may be varied. Where there is consistent compliance with emission
limits, regulators may consider reducing the frequency. However, any
significant process changes that might have affected the monitored
emission should be taken into account in making the decision.
4.19
The following should be considered when deciding whether compliance
is consistent:
a. the variability of monitoring results, for example, results which range
from 30 - 45mg/m3, against an emission limit of 50mg/m3 might not
qualify for a reduction in monitoring.
b. the margin between the results and the emission limit, for example,
results which range from 45 - 50mg/m3 when the limit is 50mg/m3
might not qualify for a reduction in monitoring.
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Consistent compliance should be demonstrated using the results from at
least;

three or more consecutive annual monitoring campaigns; or

two or more consecutive annual monitoring campaigns supported by
continuous monitoring.
Where a new or substantially changed process is being commissioned,
or where emission levels are near to or approach the emission
concentration limits, regulators should consider increasing the frequency
of testing.
4.20
A reduction in monitoring frequency should not be permitted where
continuous quantitative or indicative monitoring is required. These types
of monitoring are needed to demonstrate at all times when the plant is
operating, that either the emission limits are being complied with or that
the arrestment equipment is functioning correctly.
Monitoring of unabated releases
4.21
Where emission limit values are consistently met without the use of
abatement equipment, the monitoring requirement for those pollutants
should be dispensed with subject to the “Varying of monitoring
frequency” paragraphs above.
Representative sampling
4.22
Whether sampling on a continuous or non-continuous basis, care is
needed in the design and location of sampling systems in order to obtain
representative samples for all release points.
4.23
Where monitoring is not in accordance with the main procedural
requirements of the relevant standard, deviations should be reported.

Sampling points on new plant should be designed to comply with the
British or equivalent standards, (see paragraph 4.2).

The operator should ensure that relevant stacks or ducts are fitted
with facilities for sampling which allow compliance with the sampling
standards.
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5.
Control techniques
Summary of best available techniques
5.1
Table 5.1 provides a summary of the best available techniques that can
be used to control the process in order to meet the emission limits and
provisions in Section 4. Provided that it is demonstrated to the
satisfaction of the regulator that an equivalent level of control will be
achieved, then other techniques may be used.
Table 5.1 - Summary of control techniques
Release source
Substance
Control techniques
Oil storage and
handling
Volatile organic compounds
Siting of tank, back venting deliveries
Flue gas

Particulate matter

Abate emissions

Sulphur oxides

Limit sulphur in fuel

Carbon monoxide

Good combustion

Volatile organic compounds

Good combustion
Sources of particulate matter
Control techniques
Loading and unloading processes
Within buildings
Conveyor transport points
Suppression
Reduced drop heights


use of variable height conveyors
use of chutes
Dust arrestment


bag filters
cartridge filters
Double handling transfer points
Site and process design
Delivery to a silo
Process control for example

It is common for overcharging of silos to cause
the pressure relief valve to lift, thereby causing an
unacceptable emission
Silos



Dust arrestment

bag filters
cartridge filters

Storage silos

Within buildings

Raw material storage stockpiles
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High level monitor with alarms
Tanker delivery controls
Automatic protection system
20
Size reduction, drying and screening operations
Within process buildings
Dust arrestment

Roadways
bag filters / cartridge filters
Suppression

site and process design
External operations
Appropriate siting
conveyors

stockpiles
roadways
away from site boundary especially if
near residential or other sensitive
receptors
Wind dynamics management

Vehicles - bodies and wheels
use of fencing, bunding, profiling etc.
Wheel-wash
Exhausts that do not point vertically down
Lorries, trains
Dust covers
Techniques to control emissions from contained sources
5.2
Techniques to control emissions from contained sources
Emissions from the process operations covered by this note comprise
very fine particulate matter, in the form of dust. The main principles for
preventing dust emissions are containment of dusty processes and
suppression of dust using water or proprietary suppressants.
Suppression techniques need to be properly designed, used and
maintained in order to be effective. For example, where water is used for
dust suppression, processes should have an adequate supply of water
and all water suppression systems need adequate frost protection. To
demonstrate an adequate water supply on tanks that are not fed from the
mains a low level alarm could be fitted.
The control techniques described below address the sources of
particulate matter listed in Table 5.1.
5.3
Arrestment plant
Cyclones, wet scrubbers and bag filters can be used to abate emissions
of particulate matter to air. The industry predominantly currently uses
cyclones and wet scrubbers to achieve their emission limit of 100 mg/m3.
The cyclone separates out the coarser dust fraction and the wet arrestor
separates out the finer fraction. Such plant is usually considered BAT for
processes drying minerals with high moisture content.
Silos
5.4
The silo management system includes the high level alarms, arrestment
plant and pressure relief device. If best practice is being applied then
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any failure of the silo management system leads to full investigation of
the operation of the plant and equipment. Continuous high level
monitoring systems are currently available for use in storage silos. They
may be used telemetrically to monitor stock within the silo. They may
also be used to automatically stop delivery of material to the silo. It is
expected that such systems will become more widely used in the future.
5.5
The following measures relating to arrestment plant on silos and other
silo management techniques are only applicable where the silo vents to
the external environment or where silo emissions may escape from
inside a building into the external environment.

5.6
All dusty or potentially dusty materials should be stored in silos, in
confined storage areas within buildings, or in fully enclosed
containers / packaging. Where the storage is open within a building,
then suitable precautions should be taken to prevent wind whipping.
Delivering from road tankers to silos
Careful delivery by trained personnel will avoid materials being blown into
silos at a rate which is likely to result in pressurisation of the silo,
especially towards the end of the delivery when the quantity of material
entering the ducting is reduced. If deliveries are accepted from tankers
without on board relief valve and filtration systems, particular care to
avoid pressurisation of silos when venting air through the silo at the end
of the delivery is needed.

When delivery to a silo or bulk storage tank takes place, displaced air
should either be vented to suitable arrestment plant (for example
cartridge/bag filters) or backvented to the delivery tanker, in order to
minimise emissions. Arrestment plant fitted to silos should be of
sufficient size (and kept clean) to avoid pressurisation during
delivery.

In order that fugitive emissions are minimised during the charging of
silos, transfer lines should be securely connected to the silo delivery
inlet point and the tanker discharge point, in that order. Tanker
drivers should be informed of the correct procedures to be followed.

Bulk storage tanks and silos containing dry materials should be
equipped with audible and/ or visual high level alarms, or volume
indicators, to warn of overfilling. The correct operation of such
alarms should be checked in accordance with manufacturers'
instructions. If manufacturers‟ instructions do not specify, then the
check should be weekly or before a delivery takes place, whichever
is the longer interval.

If emissions of particulate matter are visible from ducting, pipework,
the pressure relief device or dust arrestment plant during silo filling,
the operation should cease; the cause of the problem should be
rectified prior to further deliveries taking place. Tanker drivers should
be informed of the correct procedure to be followed.
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5.7
5.8
5.9

Seating of pressure relief devices on silos should be checked at least
once a week, or before a delivery takes place, whichever is the
longer interval.

Immediately it appears that the device has become unseated during
silo filling, no further delivery should take place until corrective action
has been taken. The pressure relief device should be examined to
check for defects before being re-set and a replacement fitted if
necessary. Tanker drivers should be informed of the correct
procedure to follow.

Deliveries to silos from road vehicles should only be made using
tankers with an on-board (truck mounted) relief valve and filtration
system. This means that venting air from the tanker at the end of a
delivery will not take place through the silo. Use of alternative
techniques may be acceptable provided that they achieve an
equivalent level of control with regard to potential for emissions to air.

Care should be taken to avoid delivering materials to silos at a rate
which is likely to result in pressurisation of the silo. If compressed air
is being used to blow powder into a silo then particular care is
required towards the end of the delivery when the quantity of material
entering the ducting is reduced and hence the air flow is increased.

All new silos should be fitted with an automatic system to cut off
delivery in the event of pressurisation or overfilling. Use of alternative
techniques may be acceptable provided that they achieve an
equivalent level of control with regard to potential for emissions to air.
Aggregate storage
In areas where aggregate is being offloaded appropriate dust control
measures may include the following:

enclosure fitted with extract ventilation to arrestment plant;

enclosure fitted with water sprinklers.
Stockpiles and ground storage
Consideration should be given to the siting of stockpiles, based upon
such factors as the prevailing winds, sheltered positions, proximity of
neighbours and site operations. A method of stockpiling should be
employed which minimises dust emissions, e.g. profiling. Minimisation of
drop height is very important in stockpiling to reduce wind whipping of
particulate matter. Loading to and from stockpiles should be carried out
in such a manner as to minimise wind-borne dust e.g. taking place at
sheltered points.
When necessary to control dust emissions from stockpiles, methods such
as limiting the height of stockpiles or using dust suppressants may be
used. Other possible controls include wind breaks on stock piles,
bunding or fencing around the pile and strategic arrangement of
stockpiles. Periodic conditioning with water, according to weather
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conditions, may be an appropriate measure. Installation of fixed water
sprays should be considered for long term stocking areas if appropriate.

When using storage bays, storage height should be lower than
external walls of the bays unless suppression is provided to control
emissions.

No material should be stored in the open except for:
material that has been screened to remove material 3mm and
under;

sand;

material under 3mm that is in excess of the internal storage
capacity (the internal storage capacity should be approved by the
regulator).
Where the only practicable option for the storage of material under
3mm is external stockpiles, particularly careful consideration should
be given to the measures outlined in this guidance note.


5.10

Designated minerals that have not been screened to remove material
under 3mm should be conditioned with water or proprietary
conditioning agents at, or before, the point of discharge onto the
stockpile.

Storage areas should be kept in a condition that does not give rise to
visible dust emissions.

Unused stocking areas should also be controlled to prevent visible
dust emissions.
Conveying
There are various ways of keeping conveyor belts and the surrounding
areas clean. For example, where chevron belts are used, catch plates
may be fitted to contain dust falling from the underside of the belt at the
turning point. From a health and safety perspective this is not always
possible and hoses and sprinklers is a possible alternative. New
conveyors can be designed to minimise free fall at discharge points. A
chute, or similar equipment, at the point of discharge from a conveyor
reduces dust arising. Arrestment plant might be a suitable control option
if dusty emissions arise from conveyor transfer points. The conditions
relating to conveyors should not be applied where material has been
screened to remove particles under 3 mm in size, unless visible dust
emissions have been observed from the conveyors. The following
conditions should only be applied where emissions to the external
environment are likely to arise:
Other than deep trough ground-level conveyors carrying primary
crusher material, all conveyors should be enclosed in order to
minimise wind-whipping (i.e. at least on one side and above).
Transfer points between such conveyors should be enclosed and
fitted with flexible seals on inlet and exits.
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
5.11
5.12

Where dried materials are handled, transfer points should be ducted
to arrestment plant.

Conveyors should be fitted with effective means for keeping the
return belt clean and for collecting materials removed by this cleaning
operation. For example, belt scrapers fitted at all head drum returns
and catch plates fitted to contain falling dust.

Conveyor belts should not be overloaded.

Where the free fall of material gives rise to external dust emissions,
techniques should be used at the point of discharge to minimise this,
for example the use of a chute or similar equipment

Where dust emissions from conveyors are visible, dust suppression
equipment should be used or the plant should be vented to suitable
arrestment equipment, as agreed with the regulator.

Planned preventative maintenance schedules should include
conveyor systems.
Process operations
Emissions from the process operations covered by this note comprise
fine particulate matter, in the form of dust and the products of
combustion. The control of dust emissions from these processes is
mainly by the use of enclosures and extraction to particulate arrestment
plant. Internal transport of dusty materials should be carried out so as to
prevent or minimise airborne dust emissions, as this then reduces the
potential for fugitive emissions. The aim should be to minimise visible
dust emissions from materials handling operations. Internal transport of
dusty materials should be carried out so as to prevent or minimise
airborne dust emissions, as this then reduces the potential for fugitive
emissions.
Products of combustion are to be considered as they are prescribed
substances. Control is by burner maintenance and use of clean fuels.

All hot storage bins should have level indication and any overflow
chutes should have dust arrestment facilities fed into the main dust
arrestment system.

Equipment for the crushing, grinding and screening of minerals
should be fitted with dust extraction which is vented to air through
arrestment plant.

Plant should be designed and operated so that emission of dust
during the discharge of dried sand is minimised.

Where particulate matter emissions are abated using a wet scrubber,
the scrubber should be regularly inspected and maintained. Action
should be taken to deal with any blockages that occur due to
accumulation of solids, for example adding flocculating agents to the
liquor to settle the solids out.
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5.13
Techniques to control fugitive emissions
Fugitive dust emissions should be prevented whenever practicable.
When this is not practicable emissions should be controlled at source by
measures agreed between the regulator and the operator. Examples
include correct storage of raw materials, organising the process in such a
way that spillage is avoided, and maintaining high standards of internal
and external housekeeping. To make buildings as dust tight as
necessary to prevent visible emissions, self-closing doors and closefitting entries and exits for conveyors are among the options that may be
used. Attention should be paid to preventing and cleaning up deposits of
dust on external support structures and roofs, in order to minimise wind
entrainment of deposited dust. If necessary, emissions should be
controlled and abated using suitable arrestment equipment.

All process buildings should be made as dust tight as is necessary to
prevent visible emissions.

All process buildings should be cleaned regularly, according to a
written maintenance programme, at interval sufficient to minimise
fugitive emissions.

All new buildings housing processing machinery should be externally
clad with materials that can be readily cleaned.

Where local exhaust ventilation is used, emissions should be ducted
to suitable arrestment plant.

Dusty wastes should be stored in closed containers.

The method of collection of product or waste from dry arrestment
plant should be such that dust emissions are minimised.

A high standard of housekeeping should be maintained.

All spillages which may give rise to dust emissions should be cleaned
up promptly, normally by wet handling methods. Dry handling of
dusty spillages should not be permitted other than in fully enclosed
buildings. (NB Dry handling of dusty spillages within fully enclosed
buildings may not be acceptable under COSHH.) In the event of a
major spillage it should be dealt with on the same day that it occurs,
and measures to minimise emissions, such as wetting the surface to
create a crust, should be taken immediately.
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5.14
Loading, unloading and transport
Effective dust control measures are required for all vehicles arriving at or
leaving the site where the load may give rise to dust in transportation,
bearing in mind that emissions from moving vehicles may give rise to a
significant problem. Such controls should not normally be required for the
transportation of designated material which is above 75mm, as these
materials are unlikely to give rise to dust emissions.
5.15
Sheeting is the usual technique required to prevent dust emissions from
road vehicles. Where stone is loaded or unloaded, dust emissions should
be minimised by water suppression or by local dust extraction.
5.16
Rail wagons that are either aerodynamically designed to prevent or
virtually eliminate product blow off or "canopied" should be considered for
use when transporting such products. Application of aqueous polymer
dispersions can also provide adequate protection for such loads.
Suppression using water has been found to be adequate for short
journeys, normally of duration less than 1 hour.
5.17
A load that contains a significant amount of material less than 6mm is
considered to have a much higher potential for dust emissions during
transit than a load containing a minimal amount of this size fraction.
5.18
Where specific techniques are referred to below the regulator should
agree an alternative method provided it is demonstrated to achieve an
equivalent level of control.

Where road vehicles are used to transport potentially dusty materials,
they should be sheeted or otherwise totally enclosed as soon as
possible after loading and before leaving the site.

Where rail wagons are used to transport potentially dusty materials
the following techniques should be used to prevent emissions in
transit:

For short journeys (typically of duration less than 1 hour) or for
mineral loads with a minimal content of particles below 6mm,
water suppression will normally be sufficient.

For longer journeys or where a higher proportion of fine material
is being transported then either application of an aqueous
polymer dispersion to the surface of the load should be used, or
rail wagons that are "canopied" or aerodynamically designed to
prevent or virtually eliminate product blow off.

Where stone with the potential to give rise to dust emissions in transit
is being delivered to the quarry, the above measures should be
complied with prior to the vehicle being admitted on site.

Loading and unloading of product for transport by road, rail or sea
should be carried out so as to minimise the generation of airborne
dust.
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5.19

Tankers carrying dusty materials should discharge only into silos
fitted with an effective dust collecting system.

Internal road transport of processed materials likely to generate dust
should be carried out in closed tankers or sheeted vehicles, or the
materials conditioned with water.
Roadways
In designing a new process, minimising vehicle movement in the site
layout will enable better control of roadways with the potential for fugitive
emissions.
5.20
Vehicle exhausts directed above the horizontal are preferred as these
avoid the impact of the exhaust raising dust when travelling on internal
roadways.
5.21
On some sites wheel-cleaning facilities may be useful to prevent dust
being carried off the site. Where the plant is co-located with a quarry
which has wheel wash and underbody wash facilities available, these
might be used where necessary. If a plant is co-located with a quarry
which does not have wheel-wash facilities, it may not be appropriate to
install them. Vehicles may also be effectively cleaned, prior to leaving
site, with a brush and hose. Sometimes the presence of a long access
road ensures that any dust falls off the vehicles and does not reach the
public highway. Hard surfacing for roadways should normally comprise
compacted stone chippings between the loading points and the wheel
wash (where present), and macadam or concrete for the final section of
road leading to the public highway. Sweeping, wetting or sealing are all
techniques that may be used to reduce dust emissions from roads. The
technique that should be used depends upon the type of road under
consideration.

Roadways in normal use and any other area where there is regular
movement of vehicles should have a hard surface capable of being
cleaned or kept wet. They should be kept clean or wet, in order to
prevent or minimise dust emissions. They should be adequately
drained to avoid ponding of water. They should be kept in good
repair. This provision only applies to roads inside a working quarry to
the extent that they form part of the Part B installation. (Guidance on
the meaning of “installation “ can be found in Annex III of the
“General Guidance Manual”)

Where necessary to prevent visible dust being carried off site, wheelcleaning facilities should be provided and used by vehicles before
leaving the site.
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Air Quality
5.22
Dispersion & Dilution
Pollutants that are emitted via a stack require sufficient dispersion and
dilution in the atmosphere to ensure that they ground at concentrations
that are deemed harmless. This is the basis upon which stack heights
are calculated using HMIP Technical Guidance Note (Dispersion) D1.
The stack height so obtained is adjusted to take into account local
meteorological data, local topography, nearby emissions and the
influence of plant structure.
The calculation procedure of D1 is usually used to calculate the required
stack height but alternative dispersion models may be used in agreement
with the regulator. An operator may choose to meet tighter emission
limits in order to reduce the required stack height.
5.23
5.24
Where an emission consists purely of air and particulate matter, (i.e. no
products of combustion or any other gaseous pollutants are emitted) the
above provisions relating to stack height calculation for the purpose of
dispersion and dilution should not normally be applied. Revised stack
height calculations should not be required as a result of publication of this
revision of the PG note, unless it is considered necessary because of a
breach or serious risk of breach of an EC Directive limit value or because
it is clear from the detailed review and assessment work that the
permitted process itself is a significant contributor to the problem.
Ambient air quality management
In areas where air quality standards or objectives are being breached or
are in serious risk of breach and it is clear from the detailed review and
assessment work under Local Air Quality Management that the permitted
process itself is a significant contributor to the problem, it may be
necessary to impose tighter emission limits or, in the case of this
particular note, additional limits for pollutants not listed in table 4.1, such
as NOx. If the standard that is in danger of being exceeded is not an EC
Directive requirement, then industry is not expected to go beyond BAT to
meet it. Decisions should be taken in the context of a local authority‟s
Local Air Quality Management action plan. For example, where a
permitted process is only responsible to a very small extent for an air
quality problem, the authority should not unduly penalise the operator of
the process by requiring disproportionate emissions reductions.
Paragraph 59 of the Air Quality Strategy 2007 [Volume 1] gives the
following advice:
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“...In drawing up action plans, local authority environmental
health/pollution teams are expected to engage local authority officers
across different departments, particularly, land-use and transport
planners to ensure the actions are supported by all parts of the authority.
In addition, engagement with the wider panorama of relevant
stakeholders, including the public, is required to ensure action plans are
fit-for-purpose in addressing air quality issues. It is vital that all those
organisations, groups and individuals that have an impact upon local air
quality, buy-in and work towards objectives of an adopted action plan.”
5.25
5.26
In the context of this note PG3/18 there may be cases where, for air
quality reasons, filters rather than cyclones are considered in a particular
location, to amount to BAT
Stacks, vents and process exhausts
Liquid condensation on internal surfaces of stacks and exhaust ducts
might lead to corrosion and ductwork failure or to droplet emission.
Adequate insulation will minimise the cooling of waste gases and prevent
liquid condensation by keeping the temperature of the exhaust gases
above the dewpoint. A leak in a stack/vent and the associated ductwork,
or a build up of material on the internal surfaces may affect dispersion:

Flues and ductwork should be cleaned to prevent accumulation of
materials, as part of the routine maintenance programme.
5.27
When dispersion of pollutants discharged from the stack (or vent) is
necessary, the target exit velocity should be 15m/sec under normal
operating conditions, however, lower velocities than 15m/s are
acceptable provided adequate dispersion and dilution is achieved (see
also the paragraph below regarding wet plumes). In order to ensure
dispersion is not impaired by either low exit velocity at the point of
discharge, or deflection of the discharge, a cap, or other restriction,
should not be used at the stack exit. However, a cone may sometimes be
useful to increase the exit velocity to achieve greater dispersion.
5.28
An exception to the above is where wet arrestment is used as the
abatement. Unacceptable emissions of droplets could occur from such
plant where the linear velocity in the stack exceeds 9 m/sec. To reduce
the potential of droplet emissions a mist eliminator should be used.
Where a linear velocity of 9m/sec is exceeded in existing plant
consideration should be given to reducing this velocity as far as
practicable to ensure such droplet entrainment and fall out does not
happen.
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Management
5.29
5.30
5.31
Management techniques
Important elements for effective control of emissions include:

proper management, supervision and training for process operations;

proper use of equipment;

effective preventative maintenance on all plant and equipment
concerned with the control of emissions to the air; and

ensuring that spares and consumables - in particular, those subject
to continual wear – are held on site, or available at short notice from
guaranteed local suppliers, so that plant breakdowns can be rectified
rapidly. This is important with respect to arrestment plant and other
necessary environmental controls. It is useful to have an audited list
of essential items.
Appropriate management systems
Effective management is central to environmental performance; it is an
important component of BAT and of achieving compliance with permit
conditions. It requires a commitment to establishing objectives, setting
targets, measuring progress and revising the objectives according to
results. This includes managing risks under normal operating conditions
and in accidents and emergencies. It is therefore desirable that
installations put in place some form of structured environmental
management approach, whether by adopting published standards (ISO
14001 or the EU Eco Management and Audit Scheme [EMAS]) or by
setting up an environmental management system (EMS) tailored to the
nature and size of the particular process. Operators may also find that an
EMS will help identify business savings.
Regulators should use their discretion, in consultation with individual
operators, in agreeing the appropriate level of environmental
management. Simple systems which ensure that LAPPC considerations
are taken account of in the day-to-day running of a process may well
suffice, especially for small and medium-sized enterprises. Regulators
are urged to encourage operators to have an EMS for all their activities,
but it is outside the legal scope of an LAPPC permit to require an EMS
for purposes other than LAPPC compliance. For further
information/advice on EMS refer to the appropriate chapter of the
appropriate Guidance Manual for England and Wales, Scotland and
Northern Ireland.
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5.32
Training
Staff at all levels need the necessary training and instruction in their
duties relating to control of the process and emissions to air. In order to
minimise risk of emissions, particular emphasis should be given to
control procedures during start-up, shut down and abnormal conditions.
Training may often sensibly be addressed in the EMS referred to above.


5.33
All staff whose functions could impact on air emissions from the
activity should receive appropriate training on those functions. This
should include:

awareness of their responsibilities under the permit;

steps that are necessary to minimise emissions during start-up
and shutdown;

actions to take when there are abnormal conditions, or accidents
or spillages that could, if not controlled, result in emissions.
The operator should maintain a statement of training requirements
for each post with the above mentioned functions and keep a record
of the training received by each person. These documents should be
made available to the regulator on request.
Maintenance
Effective preventative maintenance plays a key part in achieving
compliance with emission limits and other provisions. All aspects of the
process including all plant, buildings and the equipment concerned with
the control of emissions to air should be properly maintained. In
particular:

The operator should have the following available for inspection by the
regulator:

a written maintenance programme for all pollution control
equipment; and

a record of maintenance that has been undertaken.
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6.
Summary of changes
The main changes to this note, with the reasons for the change, are
summarised in Table 6.1. Minor changes that will not impact on the
permit conditions e.g. slight alterations to the Process Description have
not been recorded.
Table 6.1 - Summary of changes
Section/
paragraph/
row
Change
Reason
Comment
Introduction
Simplification of text
Make Note
clearer
Addition of links
Change to
electronic format
Removes need for
extensive
footnotes/references
Emission limits, monitoring and other provisions
Table 4.1
Removal of limits for
waste oil
PFO complying
with the quality
protocol does not
need waste limits
Combustion of WID waste
would be a Part A2 activity
Control techniques
Clarification of exhaust
velocity requirements
Application form and simple permit
added
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33
7.
Further information
Sustainable consumption and production (SCP)
Both business and the environment can benefit from adopting
sustainable consumption and production practices.
Estimates of potential business savings include:

£6.4 billion a year UK business savings from resource efficiency
measures that cost little or nothing;

2% of annual profit lost through inefficient management of energy,
water and waste;

4% of turnover is spent on waste.
When making arrangement to comply with permit conditions, operators
are strongly advised to use the opportunity to look into what other steps
they may be able to take. Regulators may be willing to provide
assistance and ideas, although cannot be expected to act as unpaid
consultants.
Health and safety
Operators of processes and installations must protect people at work as
well as the environment:

requirements of a permit should not put at risk the health, safety or
welfare of people at work or those who may be harmed by the work
activity;

equally, the permit must not contain conditions whose only purpose
is to secure the health of people at work. That is the job of the health
and safety enforcing authorities.
Where emission limits quoted in this guidance conflict with health and
safety limits, the tighter limit should prevail because:

emission limits under the relevant environmental legislation relate to
the concentration of pollutant released into the air from prescribed
activities;

exposure limits under health and safety legislation relate to the
concentration of pollutant in the air breathed by workers;

these limits may differ since they are set according to different
criteria. It will normally be quite appropriate to have different
standards for the same pollutant, but in some cases they may be in
conflict (for example, where air discharged from a process is
breathed by workers). In such cases, the tighter limit should be
applied to prevent a relaxation of control.
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Further advice on responding to incidents
The UK Environment Agencies have published guidance on producing an
incident response plan to deal with environmental incidents. Only those
aspects relating to air emissions can be subject to regulation via a Part B
permit, but regulators may nonetheless wish to informally draw the
attention of all appropriate operators to the guidance.
It is not envisaged that regulators will often want to include conditions, in
addition to those advised in this PG note, specifying particular incident
response arrangements aimed at minimising air emissions. Regulators
should decide this on a case-by-case basis. In accordance with BAT,
any such conditions should be proportionate to the risk, including the
potential for harm from air emissions if an incident were to occur.
Account should therefore be taken of matters such as the amount and
type of materials held on site which might be affected by an incident, the
likelihood of an incident occurring, the sensitivity of the location of the
installation, and the cost of producing any plans and taking any additional
measures.
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Appendix 1 - Application form
Application for a permit for a mineral drying and cooling installation
Local Authority Pollution Prevention and Control
Pollution Prevention and Control Act, 1999
Environmental Permitting (England and Wales) Regulations 2010
Introduction
When to use this form
Use this form if you are applying for a permit to a Local Authority to operate a mineral drying and
cooling installation as defined in Schedule 1 to the Environmental Permitting Regulations.
The appropriate fee must be enclosed with the application to enable it to be processed further.
When complete, send the form and the fee and any additional information to:
*Insert local authority address*
If you need help and advice
We have made the application form as straightforward as possible, but please get in touch with us
at the local authority address given above if you need any advice on how to set out the information
we need.
For the purposes of Section H of the form, a relevant offence is any conviction for an offence
relating to the environment or environmental regulation.
LAPPC application form: to be completed by the operator
For Local Authority use
Application reference
Officer reference
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A
The basics
A1
Name and address of the installation (not required for mobile plant)
Postcode
Telephone
A2
Details of any existing environmental permit or consent (for waste operations,
include planning permission for the site, plus established use certificates, a certificate
of lawful existing use, or evidence why the General Permitted Development Order
applies.
A3
Operator details (The „operator‟ = the person who it is proposed will have control
over the installation in accordance with the permit (if granted).)
Name:
Trading name, if different:
Registered office address:
Principal office address, if different:
Company registration number:
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A4
Any holding company?
Is the operator a subsidiary of a holding company within the meaning of section 1159
of the Companies Act 2006? If “yes” please fill in details of the ultimate holding
company.
No
Yes
Name:
Trading name, if different:
Registered office address;
Principal office address, if different:
Company registration number:
A5
Who can we contact about your application? It will help to have someone who we
can contact directly with any questions about your application. The person you name
should have the authority to act on behalf of the operator - This can be an agent or
consultant.
Name and position:________________________________________________
Telephone:_______________________________________________________
Email:___________________________________________________________
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B
The installation
B1
What activities are, or will be, carried on at the installation? Please include
“directly associated activities” (this term is explained in Annex III in Part B of
the general guidance manual.
Do you dry?
a) sand
 Yes  No
b) other minerals?
 Yes  No
Is your dryer ?
a) rotary
 Yes  No
b) fluid bed
 Yes  No
Are you a toll manufacturer or jobber? (that is: the minerals you dry, do they vary
in quantity and can they change frequently depending on what customers demand?)
 Yes  No
If yes, do you dry „distressed cargo‟?
B2
Why is the application being made?


B3
 Yes  No
new installation
change to existing installation means it now needs a permit
Site maps – please provide:

A location map with a red line round the boundary of the installation
Document reference:

__________________________
A site plan or plans showing where all the relevant activities are on site:
a)
b)
where the processing plant will be installed
the areas and buildings/structures designated for materials/ waste storage and the
type of storage
c)
the conveyors and transfer points
d)
any directly associated activities or waste operations.
To save applying for permit variations, you can also show where on site you might
want to use for storage etc in the future.
Document reference: _________________
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B4
Are there any sites of special scientific interest (SSSIs) or European protected
sites nearer than any of the following distances to the proposed installation?

2km - where the installation includes one or more burners over 20MW rated
thermal input)

1km - where the installation involves mineral or cement and lime activities
 Yes  No
If „yes‟, is the installation likely to have a significant effect on these sites and, if
so, please write on a separate sheet or enclose a relevant document explaining
what the implications are for the purposes of the Conservation (Natural Habitats
etc) Regulations 1994 (see appendix 2 of Annex XVII of the general guidance
manual)
B5
Will emissions from the activity potentially have significant environmental
effects (including nuisance)?
 Yes  No
If „yes‟: list the potential significant local environmental effects (including nuisance)
of the foreseeable emissions
Document Reference: _______________________________________________

please enclose a copy of any environmental impact assessment which has been
carried out for the installation under planning legislation or for any other purpose.
Document Reference: _______________________________________________
C
The details
C1
Does your installation have arrestment equipment, with external discharge
points, , and not serving silos or dryers? (Tick all that apply)
and with a flow over 300m3/minute
 Yes  No
with a flow under 300m3/minute and over 100m3/minute
 Yes  No
under 100 m3/minute
 Yes  No
C2
Do you have continuous monitors to show compliance with a numerical limit in
Table 1 of the permit?
[informs Condition 2]
 Yes  No
If yes, do the continuous monitors have alarms which are:
Visible
 Yes  No
Audible
 Yes  No
Alarm activation recorded automatically
 Yes  No
Is a trigger level set
 Yes  No
At what percentage of the emission limit is the value set?…………………%
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Have you undertaken isokinetic sampling at least once to demonstrate
compliance with the numerical limit in Table 1?
 Yes  No
Note: “dusty material” should be taken to be any material which can be wind-entrained. It
excludes, for example, >3mm material and scalpings.
C3
In which of the following will the dried materials be stored ?:
[informs condition 5]
a) silo

b) bulk storage tank

c) within a building

d) in fully-enclosed containers/packaging

(tick all that apply)
e) other - please specify: ____________________________________________
C4
Do you have pneumatic transfer of materials?  Yes  No
[informs condition 8]
If yes, will displaced air from pneumatic loading and unloading be:
(tick all that apply)
[informs conditions 7 and 9]
a) vented to arrestment plant

b) back-vented to the delivery source

c) other - please specify: _____________________________________________
If yes to C4, do you have alarms to warn of overfilling?
[informs condition 6]
 Yes  No
If yes to C4, does pneumatic transfer automatically stop for: [informs condition 7]
a) over-filling
 Yes  No
b) over-pressurisation
 Yes  No
If pneumatic transfer doesn‟t stop automatically for over-filling and for overpressurisation, are any silos new since Jun 2004?
[informs condition 9]
 Yes  No
C5
Do you hydrograde your raw material to remove very fine particles?
 Yes  No
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C6
For materials not dealt with in condition 4-7, what facilities will be provided to
store any dusty material and waste?
(tick all that apply)
[informs condition 8]
a) hopper wind-protected on at least 3 sides

b) storage bay without suppression & stockpiles lower than retaining walls

c) storage bay with suppression

d) fully-enclosed stores

e) other - please specify: ___________________________________________
C7
Will any minerals be stored in the open (unenclosed) other than sand?
 Yes  No
[informs condition 8]
C8
Do you have belt conveyors:
 Yes  No
[informs condition 9]
If yes, which of the following facilities will be provided to convey any dusty
material and waste (tick all that apply)
[informs condition 9]
a) deep trough ground-level conveyor

b) fully-enclosed conveyor

c) pneumatic handling system

d) bucket elevator

e) wind boards

f) other – please specify: _____________________________________________
C9
Which of the following methods will be used to minimise emissions at belt
conveyor transfer points, including free fall of material?
(tick all that apply)
[informs condition 9]
a) enclosed

b) enclosed and ducted to arrestment equipment

c) fitted with a chute

d) other - please specify: ______________________________________________
C10 Which of the following techniques will be used to clean belt conveyors
(tick all that apply)
[informs condition 9]
a) belt scrapers

b) catch plates

c) other techniques for keeping the return belt clean and collecting the material
removed by the cleaning – please specify:
__________________________________________________________________
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C11 How will potentially dusty materials (including any raw materials, finished
products and waste), arrive at or leave the site? (tick all that apply)
[informs Condition 10]
Raw Materials
Finished Products
Waste
Road
Rail
Other
C12 How will potentially dusty materials, (including any raw material, finished
products and waste) be transported within the site?
(tick all that apply)
[informs condition 10]
a) tanker

b) fully-enclosed transport

c) „canopied‟ rail wagons

d) sheeted transport

e) water suppression applied to the transported material

f) aqueous polymer suppression applied to the transported material

g) bagged

h) other – please specify: ______________________________________________
C13 Which techniques will you use to ensure that vehicles do not track material onto
the highway?
[informs condition 12]
a) body and wheel wash

b) wheel wash

c) hose and brush

d) sufficient distant to the site boundary on sealed road before leaving site 
e) other, please describe: _______________________________________________
C14 Do you use any of the following fuels? (tick all that apply) [informs stack height]
a) heavy fuel oil

b) gas oil

c) gas

d) processed fuel oil

e) other waste derived fuel

f) other (give details): ______________________________________________
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What is the rated thermal input of dryers? Please specify:
________________________________________________________________
C15 Do you have environmental management procedures and policy?
 Yes  No
[informs condition 14]
D
Anything else
Please tell us anything else you would like us to take account of.
Document Reference
E
_____________________________________
Application fee
You must enclose the relevant fee with your application.
If your application is successful you will also have to pay an annual subsistence charge, so
please say who you want invoices to be sent to.
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F
Protection of information
F1
Any confidential or national security info in your application?
If there is any information in your application you think should be kept off the public register
for confidentiality or national security reasons, please say what and why. General guidance
manual chapter 8 advises on what may be excluded. (Do not include any national security
information in your application. Send it, plus the omitted information, to the Secretary of
State or Welsh Ministers who will decide what, if anything, can be made public.)
Document Reference:
_____________________________
F2
Please note: data protection
The information you give will be used by the Council to process your application. It will be
placed on the relevant public register and used to monitor compliance with the permit
conditions. We may also use and or disclose any of the information you give us in order to:
 consult with the public, public bodies and other organisations,

carry out statistical analysis, research and development on environmental issues,

provide public register information to enquirers,

make sure you keep to the conditions of your permit and deal with any matters
relating to your permit

investigate possible breaches of environmental law and take any resulting action,

prevent breaches of environmental law,

offer you documents or services relating to environmental matters,

respond to requests for information under the Freedom of Information Act 2000 and
the Environmental Information Regulations 2004 (if the Data Protection Act allows)

assess customer service satisfaction and improve our service.
We may pass on the information to agents/representatives who we ask to do any of these
things on our behalf.
F3
Please note: it is an offence to provide false etc information
It is an offence under regulation 38 of the EP Regulations, for the purpose of obtaining a
permit (for yourself or anyone else), to:
 make a false statement which you know to be false or misleading in a material
particular,

recklessly make a statement which is false or misleading in a material particular

intentionally to make a false entry in any record required to be kept under any
environmental permit condition

with intent to deceive, to forge or use a document issued or required for any purpose
under any environmental permit condition.
If you make a false statement

we may prosecute you, and

if you are convicted, you are liable to a fine or imprisonment (or both).
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H
Declarations A and B for signing, please
These declarations should be signed by the person listed in answer to question A3. Where more
than one person is identified as the operator, all should sign. Where a company or other body
corporate is the operator, an authorised person should sign and provide evidence of authority from
the board.
Declaration A:
I/We certify
EITHER – As evidence of my/our competence to operate this installation in accordance with the
EP Regulations, no offences have been committed in the previous five years relating to the
environment or environmental regulation.
OR- The following offences have been committed in the previous five years which may be relevant
to my/our competence to operating this installation in accordance with the regulations:
______________________________________________________________________________
Signature:
Name:
Position:
Date:
_______________________________
______
_______
Declaration B: I/We certify that the information in this application is correct. I/We apply for a
permit in respect of the particulars described in this application (including the listed supporting
documentation) I/we have supplied. (Please note that each individual operator must sign the
declaration themselves, even if an agent is acting on their behalf.)
Signature:
Name:
Position:
Date:
Signature:
Name:
Position:
Date:
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_______________________________
______
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46
Appendix 2 - Model Permit
This appendix contains a model permit for mineral drying and cooling installations – see para 1.6 of
this note and para 3.6 of the General Guidance Manual on Policy and Procedures .
Notes:

text in the model permit written in italics is advice to regulators.

text in the model permit in square brackets offers choice to regulators or indicates where
information needs to be inserted from the application.

text bracketed with asterisks (eg *Alarms shall be tested at least once a week*.) may be
omitted by a regulator where the past performance of the plant gives the local authority
sufficient reassurance about operator compliance – “earned recognition”.

the model permit has been drafted for local authorities in England and Wales. Regulators
in Scotland and Northern Ireland will need to amend the legal heading and, where
appropriate, references to „Council‟

references to „installation‟ will need to be substituted with „mobile plant‟ in relevant cases,
and other amendments made accordingly

the purpose of the activity description is to set down the main characteristics of the activity,
including any directly associated activities, so it is clear to all concerned what is being
authorised by the permit and therefore what changes would need further approval.
Regulators are advised to include a description of any key items of arrestment and
monitoring equipment the operator intends to use or is using.

it should normally be sufficient for records relating to simplified permits to be kept for no
more than 18 months. Where, however, as a result of a „low risk‟ rating, inspections are
undertaken less often, regulators may want to specify a period which ensures the records
are available at the next inspection.
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[ ] COUNCIL
POLLUTION PREVENTION AND CONTROL ACT 1999
Environmental Permitting Regulations 2010 (as amended)
Permit ref. no:
Name and address of person (A) authorised to operate the installation („the operator‟)
Registered number and office of company (if appropriate)
Address of permitted installation (B)
The installation boundary and key items of equipment mentioned in permit conditions are shown in
the plan attached to this permit.
Activity description
The operator (A) is authorised to operate the activity4 at the installation (B) subject to the following
conditions.
Conditions
Emissions and monitoring
1.
No visible particulate matter shall be emitted beyond the installation boundary.
2.
The emission requirements and methods and frequency of monitoring set out in Table 1 shall
be complied with.
Any monitoring display required for compliance with the permit shall be visible to operating
staff at all times. Corrective action shall be taken immediately if any periodic monitoring result
exceeds a limit in Table 1, or if there is a malfunction or breakdown of any equipment which
might increase emissions. Monitoring shall be undertaken or repeated as soon as possible
thereafter and a brief record shall be kept of the main actions taken.
Where continuous monitors are fitted to show compliance with a numerical limit in Table 1: All
continuous monitors fitted to show compliance with the permit shall be fitted with a [visible]
[audible] alarm warning of arrestment failure or malfunction. They shall [activate when
emissions reach [75%] of the relevant emission limit in Table 1 and] record automatically each
activation. *Alarms shall be tested at least once a week.*
4
listed in [
] in Part 2 of Schedule 1 to the Environmental Permitting Regulations
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3.
All plant and equipment capable of causing, or preventing, emissions and all monitoring
devices shall be calibrated and maintained in accordance with the manufacturer‟s instructions.
*Records shall be kept of such maintenance.*
Silos where used
4.
Dried materialst shall only be stored within the product silos.
5.
Dust emissions from loading or unloading road tankers shall be minimised by [venting to
specify type arrestment plant] [backventing to a delivery tanker fitted with an on-board, truckmounted relief valve and filtration system] and by connecting transfer lines first to the delivery
inlet point and then to the tanker discharge point, and by ensuring delivery is at a rate which
does not pressurise the silo.
6.
Silos and bulk containers of dusty materials shall not be overfilled and there shall be an
overfilling alarm. When loading silos which were new after Jun 2004, deliveries must
automatically stop where overfilling or over-pressurisation is identified.
7.
Displaced air from pneumatic transfer shall pass through abatement plant prior to emission to
air.
Aggregates delivery and storage
8.
Dusty materials (including dusty wastes) shall only be stored in [specify storage location] as
detailed on the plan attached to this permit and shall be subject to suppression and
management techniques to minimise dust emissions.
9.
Unused stocking areas shall also be controlled to prevent visible dust emissions
Belt conveying
10. All dusty materials, including wastes, shall be conveyed using [specify conveyor, level of
enclosure and enclosure type]. All transfer points shall be fitted with [specify dust control
technique].
Loading, unloading and transport
11. No potentially dusty materials (including wastes) or finished products shall arrive on or leave
the site other than by use of [specify transport type and dust control technique].
Roadways and transportation
12. All areas where there is regular movement of vehicles shall have a consolidated surface
capable of being cleaned, and these surfaces shall be kept clean and in good repair.
13. Vehicles shall not track material from the site onto the highway.
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Techniques to control fugitive emissions
14. Select according to visible dust potential of each process building. The fabric of [process
buildings] shall be maintained so as to minimise visible dust emissions
Records and training
15. Written or computer records of all tests and monitoring shall be kept by the operator for at
least [ ] months. They [and a copy of all manufacturer‟s instructions referred to in this permit]
shall be made available for examination by the Council. *Records shall be kept of operator
inspections, including those for visible and odorous emissions.*
16. Staff at all levels shall receive the necessary training and instruction to enable them to comply
with the conditions of this permit. Records shall be kept of relevant training undertaken.
The following two conditions are not needed for PPC permits which transferred automatically into
the environmental permitting regime by virtue of regulation 69(6) of the 2007 Regulations and
regulation 108(4) of the 2010 Regulations. Where permits are issued on or after 6 April 2008 the
next two conditions will not automatically apply and need specific inclusion in the permit where
required.
Best available techniques
17. The best available techniques shall be used to prevent or, where that is not practicable,
reduce emissions from the installation in relation to any aspect of the operation of the
installation which is not regulated by any other condition of this permit.
18. If the operator proposes to make a change in operation of the installation, he must, at least 14
days before making the change, notify the regulator in writing. The notification must contain a
description of the proposed change in operation. It is not necessary to make such a
notification if an application to vary this permit has been made and the application contains a
description of the proposed change. In this condition „change in operation‟ means a change in
the nature or functioning, or an extension, of the installation, which may have consequences
for the environment.
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Row
Table 1 - Emission limits, monitoring and other provisions
Substance
Source
Emission limits/provisions
Type of monitoring
Monitoring
frequency
Whole site and all authorised emission points
1
Visible
emissions
Site
No visible emissions to cross site
boundary
Operator observations
2
Visible
emission
All authorised emission
points
No abnormal emission
Operator observations
3
Droplets,
persistent
mist fume
and smoke
4
Particulate
matter
All emissions to air (except No droplets, no persistent mist, no
steam and condensed
persistent fume,
water vapour)
No visible smoke except during start
up of dryers and then no darker than
Ringelmann 1
Sand and Mineral Drying plant
Sand and Mineral Drying
plant, other than Fluid Bed
Dryers
50 mg/m3
Once a day
Visual observations
On start-up and
on at least two
more occasions
during the
working day
EITHER: periodic particulate
monitoring
6 monthly
OR periodic particulate monitoring
Annual
plus: continuously recorded indicative
monitoring
5
Particulate
matter
Sand and Mineral Drying
plant, Fluid Bed Dryers
Where 50mg/m3 is currently
achieved, but only inconsistently:
EITHER: periodic particulate
monitoring
6 monthly
100mg/m3 PLUS efforts should be
made to improve consistency.
OR periodic particulate monitoring
Annual
plus: continuously recorded indicative
monitoring
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7
Sulphur
dioxide
All activities using heavy
fuel oil or other residual
type/comparable Quality
Protocol Processed Fuel
Oil
1% wt/wt sulphur in fuel
All activities using gas oil/
comparable Quality
Protocol Processed Fuel
Oil
0.1% wt/wt sulphur in fuel
Sulphur content of fuel is regulated under the Sulphur
Content of Liquid Fuels Regulations
Activities burning waste oil not covered by the quality protocol processed fuel oil must comply with the Waste Incineration Directive (WID).
Silos
8
Particulate
matter
Silo inlets and outlets
No visible emission
Designed to emit less than 10mg/m3
Operator/driver observations every
delivery. Record start and finish times
Every delivery
Arrestment equipment, not serving silos or dryers, and with external discharge points
9
Particulate
matter
Flow 300m3/min or
more
10
Particulate
matter
11
Particulate
matter
Designed to achieve 50mg/m3
recorded filter leak monitoring
Continuous
Flow more than
Designed to achieve 50mg/m3
100m3/min and less than
300m3/min
At least recorded indicative monitoring
Continuous
Flow100m3/min or less
Operator observations
At least daily
Or, recorded indicative monitoring
Continuous
No visible emission
Notes
*All periodic monitoring results shall be checked by the operator on receipt and sent to the Council within 8 weeks of the monitoring being
undertaken.*
The reference conditions for limits in Table 1 are: 273.1K, 101.3kPa, without correction for water vapour content, unless stated otherwise,
All periodic monitoring shall be representative, and shall use standard methods.
The emission limits do not apply during start-up and shut down. All emissions shall be kept to a minimum during these periods.
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Right to Appeal
You have the right of appeal against this permit within 6 months of the date of the decision. The
Council can tell you how to appeal [or supply details with the permit]. You will normally be expected to
pay your own expenses during an appeal.
You will be liable for prosecution if you fail to comply with the conditions of this permit. If found guilty,
the maximum penalty for each offence if prosecuted in a Magistrates Court is £50,000 and/or 6 months
imprisonment. In a Crown Court it is an unlimited fine and/or 5 years imprisonment.
Our enforcement of your permit will be in accordance with the Regulators‟ Compliance Code.
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